Safety professionals put a lot of work into creating a safe and productive environment for their employees. Every now and then, you need to be ready for OSHA to arrive and put your safety compliance protocols to the test.

This can often be a nerve-racking ordeal, as no one wants a minor slip-up or issue to lead to greater consequences down the road. But an OSHA inspection doesn’t have to be a stressful process, especially if you take all the right steps to properly prepare.

Here’s what you can expect from an OSHA inspection and what you can do to make sure your business is ready at every turn.

Pre-planning before OSHA arrives

It’s important to first know who will be conducting your OSHA inspection. An OSHA Compliance Safety and Health Official (CSHO) will be the lead inspector – and they typically do their homework. By the time the CSHO arrives at your facility, there’s a good chance he or she will already be aware of the complete compliance history of your organization.

The inspection is largely facilitated via Chapter 3 of OSHA’s Field Operations Manual (FOM), which essentially serves as OSHA’s playbook for workplace compliance. It’s important all safety personnel within your organization are familiar with this document and how it will come into play during an inspection.

Here are a few steps OSHA takes before they show up:

  • Review of your company’s OSHA inspection history
  • Obtaining of any OSHA Data Initiative (ODI) survey information
  • Review of your worksite for voluntary participation in OSHA Star, Merit, or SHARP programs
  • Obtaining of administrative subpoena/medical access orders and warrants if needed

Before the inspection, you should:

  • Address any security clearance needs that will allow the CSHO to enter the worksite.
  • Create an inspection kit to use during the inspection that may include a digital camera, measuring tape, pen, paper, etc.
  • Identify the scope of the inspection (if it’s comprehensive or partial, if there’s a specific reason for it, etc.). This can help set your expectations and inform your preparation process.

What to do when OSHA arrives

When OSHA arrives for an inspection, you should first verify the CSHO’s credentials. They will have with them government-issued ID and business cards. Once verified, you then have two options: to either proceed with the inspection or to turn the CSHO away to obtain a court-ordered subpoena.

It is highly recommended that you let the CSHO in to conduct the inspection, unless clearly directed otherwise from your organization’s leadership. Note that you do have the right to an inspection conducted at a reasonable time and in a reasonable manner (i.e. during regular business hours).

If you decide to proceed with the inspection, you should inform all team members and subcontractors – and especially leadership – that OSHA is on the premises before allowing the inspection to officially begin. Keep in mind that OSHA doesn’t have to wait for any set amount of time to begin the inspection, so be quick in informing your team so as to start things off in a positive manner. Be cooperative with the CSHO and treat them as you would a guest in your house.

Opening conference

The OSHA inspection will begin with an opening conference. This presents an opportunity to further understand the purpose of the inspection. Is it due to a complaint or accident or is it simply a follow-up? Take notes during the opening conference to record the CSHO’s initial objectives.

Make sure you ask any questions and state all requirements you have during the opening conference, such as trade secret information. Once the opening conference is completed, employers lose their right to make this demand.

Document review

It’s then common for the CSHO to review documents to gain a clear picture of your organization’s current and past safety compliance. This may include:

  • Verification of your worksite’s Standard Industrial Classification (SIC or NAICS) Code
  • Review of OSHA logs , 301 incident forms, and 300A summaries for at least the last three years
  • Request to view a roster of all current employees
  • Request to view a copy of a hazard assessment or certification statement with the person who completed it
  • Review of any respiratory protection needs and requirements
  • Questions asked of you may include:
  • What are the total hours worked for the site?
  • What is the total number of employees worked for each year?
  • Does the establishment have an onsite medical facility?
  • Where is the nearest emergency room where employees may be treated?
  • Is a workplace violence program in place? What are you doing to address this potential hazard?

Worksite walkthrough

From there, a walkthrough of the facility is typically the next step. Assign two team members to meet with and accompany the CSHO during the inspection – one to take notes and one to stay with the inspector. These employees should be knowledgeable as to where records are located, what your safety practices and history are, etc.

Plan to take the most direct route through the work area. During this time, the CSHO will examine your equipment and workplace practices and may also decide to conduct interviews with employees. If this does occur, make sure interviews take place in a private space away from the working environment.

OSHA is able to privately interview hourly employees, but management/salaried employees may have a company representative with them during any deposition or interview.

If you are interviewed:

  • Make sure you understand a question before answering
  • Provide honest, straightforward answers based on fact and what you know
  • Don’t speculate or volunteer additional information or opinions

Make sure you never leave the CSHO unattended in your facility, and take notes of everything that takes place during the walkthrough.

Closing conference

The last phase of the OSHA inspection is the closing conference, which usually occurs the day of the inspection. During this time, you should feel encouraged to ask the CSHO about any findings from the inspection and should also request copies of photos taken or materials completed during the walkthrough.

Remember – the inspector can’t issue citations. Only the area director can. However, the CSHO can provide recommendations to the director, so it’s important to impress them and leave them feeling confident in the safety practices of your organization.

Ace your next OSHA inspection with help from Fit For Work

If your business is in need of a safety compliance easy button, we can help. Fit For Work partners with organizations like yours all across the country to find the gaps, get you to compliance, and make sure you stay there. Whether you’re in need of a Job Safety Analysis or expert-led OSHA training , we have the resources needed to lead you through the process from start to finish.

Contact us today begin identifying and mitigating hazards to ensure your business is more than ready for your next inspection.

Download the infographic for an in-depth look at the standards and regulations set forth by OSHA in preparation for an inspection. 

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